Justia Civil Rights Opinion Summaries

Curtis Walker, who was 17 years old when he committed murder, was sentenced to life in prison with a parole eligibility date set for 2071, effectively making it a life-without-parole sentence. After serving nearly 30 years, Walker sought postconviction relief, arguing that his sentence violated the Eighth Amendment based on a series of Supreme Court decisions regarding juvenile offenders sentenced to life without parole. Walker's request for a "meaningful opportunity" to demonstrate his rehabilitation was denied by the Wisconsin state courts, prompting him to file a federal habeas corpus petition.The Wisconsin Court of Appeals denied Walker's postconviction motion, holding that his sentence did not violate the Eighth Amendment because the sentencing judge had considered his youth and its attendant circumstances. The Wisconsin Supreme Court denied review. Walker then filed a federal habeas petition, which the district court dismissed as untimely and without merit, concluding that the Wisconsin Court of Appeals did not unreasonably apply federal law.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's denial of habeas relief. The court held that the Wisconsin Court of Appeals did not unreasonably apply Supreme Court precedent, particularly in light of the decisions in Miller v. Alabama, Montgomery v. Louisiana, and Jones v. Mississippi. The Seventh Circuit concluded that the state court's decision was not contrary to or an unreasonable application of clearly established federal law, as the Supreme Court's precedents did not clearly establish a categorical prohibition against sentencing corrigible juvenile offenders to life without parole. View "Walker v Cromwell" on Justia Law

Marqus Patton was convicted by a Nebraska jury of first-degree murder and using a deadly weapon during a robbery following the attempted robbery and fatal shooting of Kristopher Winters. Patton filed a habeas corpus petition under 28 U.S.C. § 2254(d), alleging that his due process rights were violated because the State failed to disclose tacit plea agreements with two witnesses, Emily Gusman and Drake Northrop, who testified against him at trial.The United States District Court for the District of Nebraska denied Patton’s habeas petition but granted a certificate of appealability. The district court was skeptical about the absence of agreements but concluded that the Nebraska Supreme Court’s finding that no tacit plea agreements existed was not unreasonable. The district court also found that any undisclosed agreements would not have been material to the trial's outcome due to the extensive cross-examination of the witnesses.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court noted that the Nebraska Supreme Court had determined there were no tacit plea agreements, and this conclusion was not unreasonable based on the evidence. The court emphasized that under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), a state court’s factual determinations are presumed correct unless rebutted by clear and convincing evidence. The Eighth Circuit found that the evidence supported either conclusion regarding the existence of tacit plea agreements and that the state court’s determination was reasonable.The Eighth Circuit affirmed the district court’s denial of Patton’s habeas petition, concluding that the state court’s adjudication did not involve an unreasonable determination of the facts. View "Patton v. Boyd" on Justia Law

Brandon Duane Wagstaff was convicted by a jury of felony false imprisonment and related offenses stemming from a domestic violence incident. The trial court sentenced him to 16 months in prison. Wagstaff, who is Black, claimed that the trial court violated the California Racial Justice Act of 2020 (RJA) during various stages of the proceedings. However, his trial counsel did not object to these statements under the RJA, leading to the forfeiture of these claims on appeal. Wagstaff also argued that his trial counsel was ineffective for not objecting to a specific statement made by the trial court at sentencing, but the appellate court found this claim to be without merit.In the lower court, the prosecution charged Wagstaff with five counts, including felony false imprisonment, attempted second-degree robbery, contempt of court, threatening to commit a crime, and battery upon a person in a dating relationship. The jury found him guilty on four counts but acquitted him of attempted robbery. Wagstaff admitted to a prior conviction, and the trial court imposed an aggregate sentence of nine years and four months, including a term from a separate case.The California Court of Appeal, Sixth Appellate District, reviewed the case. The court held that Wagstaff's claims under the RJA were forfeited due to the lack of objections by his trial counsel. The court also concluded that the trial court's failure to instruct the jury on misdemeanor false imprisonment as a lesser included offense was not erroneous because there was no substantial evidence to support such an instruction. The appellate court affirmed the judgment, finding no merit in Wagstaff's claims. View "P. v. Wagstaff" on Justia Law

In 2015, Shirley Carter was found dead in her home from gunshot wounds. Jason Carter, her son, was later found civilly liable for her wrongful death. Following this, Iowa Division of Criminal Investigation Agent Mark Ludwick and Marion County Deputy Sheriff Reed Kious arrested Jason for first-degree murder. However, Jason was acquitted in a jury trial. Jason then filed a 42 U.S.C. § 1983 action against Ludwick and Kious, alleging violations of his constitutional and state-law rights during the investigation of his mother's murder.The United States District Court for the Southern District of Iowa dismissed Jason's complaint, granting Ludwick and Kious qualified immunity on all federal claims and ruling that Jason failed to state a claim for his state law claims. The court also dismissed Marion County from the suit, as Jason did not allege a pattern of unconstitutional conduct.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court's dismissal, holding that Ludwick and Kious were entitled to qualified immunity. The court found that Jason failed to plausibly allege a constitutional violation for false arrest, as the arrest was conducted pursuant to a facially valid warrant. The court also held that Jason's claim of evidence concealment did not constitute a clearly established constitutional violation. Additionally, the court ruled that Jason's failure-to-investigate claim did not meet the threshold for a substantive due process violation. The court also affirmed the dismissal of Jason's state law claims for malicious prosecution and abuse of process, noting the presence of probable cause and the lack of improper motive. View "Carter v. Ludwick" on Justia Law

The defendants in this case challenged the constitutionality of 8 U.S.C. § 1326, which criminalizes unlawfully reentering the United States after a prior removal. They argued that the statute violates the equal protection component of the Fifth Amendment’s Due Process Clause by discriminating against Mexican and other Latin American immigrants. Their theory was that the statute’s predecessor, the Undesirable Aliens Act of 1929, was enacted with discriminatory intent, and that § 1326, first codified in 1952 and amended several times thereafter, perpetuates that taint.The United States District Court for the Middle District of Florida denied the defendants’ motions to dismiss their indictments. The court assumed without deciding that the Arlington Heights framework applied but concluded that the defendants had failed to establish a discriminatory purpose behind § 1326’s enactment. The court also concluded that the statute easily satisfied rational-basis review. The defendants then entered conditional guilty pleas or proceeded to a stipulated bench trial, reserving their rights to appeal the constitutional issue. The District Court sentenced the defendants to varying terms of imprisonment and supervised release.The United States Court of Appeals for the Eleventh Circuit reviewed the case and upheld the District Court’s decision. The court found no clear error in the District Court’s conclusion that the defendants had not shown that § 1326 was enacted or maintained for a discriminatory purpose. The court noted that the defendants’ evidence, including historical context, statements by public officials, and statistical disparities, was insufficient to establish that the 1952 Congress acted with discriminatory intent. The court also emphasized that laws do not carry forward “taint” through reenactment unless the later legislature acted with the same constitutionally impermissible purpose. The judgments of the District Court were affirmed. View "USA v. Ferretiz-Hernandez" on Justia Law

Aarin Clinkscale was indicted in 2014 for his involvement in an armed robbery that resulted in two deaths. He pled guilty to aggravated robbery with a firearm specification and two counts of involuntary manslaughter. In 2016, the trial court sentenced him to a total of 14 years in prison, including a mandatory three-year term for the firearm specification. Clinkscale received 762 days of jail-time credit for time served prior to sentencing.Clinkscale filed his first motion for judicial release in June 2020, which the trial court denied, stating he would be eligible for release in October 2022. He filed a second motion for judicial release in October 2022. The State objected, arguing that Clinkscale was not eligible until November 2024, as he needed to serve the mandatory term and then wait five years. The trial court granted Clinkscale’s motion, and the State appealed to the Tenth District Court of Appeals. The appellate court affirmed the trial court’s decision, concluding that Clinkscale’s jail-time credit shortened the waiting period for judicial release.The Supreme Court of Ohio reviewed the case and disagreed with the Tenth District’s conclusion. The court held that jail-time credit does not reduce the required five-year waiting period following the expiration of mandatory prison terms under R.C. 2929.20(C)(1)(d). The court emphasized that the five-year waiting period is fixed and begins only after the mandatory term is completed. Consequently, Clinkscale’s motion for judicial release was premature. The Supreme Court of Ohio reversed the judgment of the Tenth District Court of Appeals and remanded the case for consideration of Clinkscale’s equal-protection argument. View "State v. Clinkscale" on Justia Law

The appellant was convicted of felony murder, armed robbery, and other crimes related to the shooting death of Sean Turner and the robbery of Turner and Stephen Thomas. The crimes occurred on December 4, 2015, and the appellant was indicted on multiple counts, including malice murder, felony murder, armed robbery, aggravated assault, hijacking a motor vehicle, and possession of a firearm during the commission of a felony. The jury found the appellant guilty on all counts except malice murder and two counts of aggravated assault. The trial court sentenced the appellant to life in prison for felony murder, along with additional concurrent and consecutive sentences for other charges.The appellant filed a motion for a new trial, which was denied by the trial court. The appellant then appealed to the Supreme Court of Georgia, arguing that the evidence was insufficient to support his convictions, that the trial court erred in several respects, and that his trial counsel was ineffective.The Supreme Court of Georgia reviewed the case and found that the evidence was sufficient to support the appellant's convictions for felony murder and armed robbery. The court also found that the trial court did not commit plain error by failing to charge the jury on accomplice corroboration, as the accomplice's testimony was corroborated by other evidence. Additionally, the court held that the appellant's Sixth Amendment right to confront witnesses was not violated, as the co-indictee who refused to testify was never brought before the jury. The court also found that any error in admitting testimony about the appellant's alleged gang involvement was harmless.Regarding the claims of ineffective assistance of counsel, the court found that the appellant's counsel was not deficient in failing to file a general demurrer, request an accomplice corroboration charge, renew an objection to the trial court's refusal to instruct the jury on voluntary manslaughter, or move to exclude evidence of a handgun. The court concluded that the appellant did not suffer cumulative prejudice from the alleged errors and affirmed the convictions. View "FLOYD v. THE STATE" on Justia Law

Gregory Wilson was convicted by a jury of multiple charges, including human trafficking of a minor by force or fear, human trafficking to commit another crime, kidnapping, and criminal threats. He was sentenced to an aggregate determinate term of 31 years and eight months, followed by an indeterminate term of 30 years to life. Wilson appealed, arguing that his defense counsel was ineffective for not objecting to the prosecutor's use of the term "gorilla pimp" during closing arguments, which he claimed violated the Racial Justice Act (RJA).The trial court had found Wilson guilty based on substantial evidence, including testimonies from victims B.W., K.W., and B.C., who described being forced into prostitution through violence and threats. The jury found Wilson not guilty of rape and forcible oral copulation but convicted him on other charges. The trial court sentenced him accordingly.The California Court of Appeal, Second Appellate District, reviewed the case. The court concluded that defense counsel was not ineffective as a matter of law for failing to object to the prosecutor's use of the term "gorilla pimp." The court reasoned that the term is a recognized term of art in the sex trafficking subculture, describing a pimp who uses force and violence. The court also noted that the issue of ineffective counsel should be resolved in a habeas corpus proceeding, where defense counsel can explain their conduct.The appellate court affirmed the trial court's judgment, finding substantial evidence supporting Wilson's convictions for human trafficking and kidnapping. The court also rejected Wilson's claims regarding sentencing, including the argument that the trial court abused its discretion and violated section 654's prohibition against multiple punishments. View "People v. Wilson" on Justia Law

DeShawn Gervin was on probation in Georgia with the sole condition that he not return to the South Georgia Judicial Circuit. He moved to North Carolina but was later imprisoned there for various crimes. A Georgia probation officer, Pamela Florence, learned of his North Carolina offenses and sought a warrant for his arrest in Georgia, falsely claiming he had violated probation by failing to report. Gervin was arrested in North Carolina and extradited to Georgia, where he spent 104 days in jail before a court found he had not violated his probation and ordered his release.Gervin sued Florence and another probation officer, Tandria Milton, under 42 U.S.C. § 1983, alleging violations of his Fourth, Eighth, and Fourteenth Amendment rights. The United States District Court for the Middle District of Georgia granted summary judgment for the defendants on the Eighth and Fourteenth Amendment claims but denied it on the Fourth Amendment claim, characterizing it as a malicious-prosecution claim.The United States Court of Appeals for the Eleventh Circuit affirmed the district court's ruling. The court held that Gervin presented enough evidence to support his Fourth Amendment malicious-prosecution claim. The court found that Florence and Milton recklessly made false statements and omissions that led to Gervin's arrest and prolonged detention, violating his Fourth and Fourteenth Amendment rights. The court also concluded that the probation officers were not entitled to qualified immunity because the constitutional violations were clearly established at the time of their actions. View "Gervin v. Florence" on Justia Law

The case involves Deliezha Davonte Gravely, who was pulled over by a police officer for speeding. During the stop, the officer discovered that Gravely was driving with a revoked license due to a DUI and found a loaded firearm in his pocket. Gravely was subsequently indicted on multiple charges, including unlawful possession of a firearm by a prohibited person and carrying a concealed firearm by a prohibited person, based on his prior conviction for conspiracy to commit first-degree robbery.The Circuit Court of Mercer County ruled that Gravely's prior conviction for conspiracy to commit first-degree robbery qualified as a "felony crime of violence against the person of another" under West Virginia Code § 61-7-7(b). Gravely was convicted by a jury on all counts and sentenced to imprisonment. He appealed, arguing that the circuit court erred in classifying his conspiracy conviction as a crime of violence.The Supreme Court of Appeals of West Virginia reviewed the case de novo, focusing on whether the elements of conspiracy under West Virginia Code § 61-10-31 include a violent act against a person. The court applied the elements test from State v. Mills, which requires examining the statutory elements of the predicate offense rather than the specific conduct of the defendant. The court found that the elements of conspiracy—an agreement to commit an offense and an overt act to effect the conspiracy—do not require a violent act against a person.The Supreme Court of Appeals of West Virginia held that conspiracy to commit first-degree robbery is not a "felony crime of violence against the person of another" for the purposes of West Virginia Code § 61-7-7(b). Consequently, the court reversed Gravely's convictions for unlawful possession of a firearm by a prohibited person and carrying a concealed firearm by a prohibited person, and remanded the case for resentencing on his remaining convictions. View "State v. Gravely" on Justia Law